Earlier today, a HUD official sent an email to Executive Directors at MTW agencies providing additional guidance on when it is appropriate for MTW agencies to access HUD-held reserves. The guidance is reproduced below.
Dear Executive Director,
The letter sent to your PHA dated January 15th regarding access to the HHR and setting out criteria for requesting HHR applies to MTW and non-MTW PHAs. During a lapse in appropriations, HUD staff is only permitted to work on certain activities, including activities that address threats to human lives and properties. As an MTW PHA, if you believe you need access to the HHR to address immediate threats to the health and safety of tenants or the preservation of property beyond those in the January 15th letter, please submit the amount, a justification for the amount, the intended programmatic use (e.g., public housing, low-income housing), and the timing of expenditure to Robert Boepple at email@example.com.
Earlier today, HUD sent an email to Executive Directors informing them that those PHAs administering Housing Choice Voucher (HCV) programs may access their HUD-held Housing Assistance Payment Reserves (HHR) under certain circumstances. In those instances where scheduled payments (for January and February) are not sufficient to meet a program’s Housing Assistance Payment (HAP) need, PHAs may access their reserves.
Specifically, in situations where a failure to act “would result in an imminent threat to the safety of human life or the protection of property,” PHAs may request their HAP reserves from HUD in the following instances:
- To protect families that are at imminent risk of termination; or
- PHAs that were eligible to receive a payment for January 2019 and did not receive it (e.g., first time Rental Assistance Demonstration (RAD) payment) and need reserves to ensure that the property owner(s) receives a HAP payment to continue assistance and protect the residents at the property.
These funds may only be used for HAP funding. To request the additional payment, please contact Robert.H.Boepple@hud.gov. The request should include the following:
- amount of the payment;
- supporting monthly leasing projections;
- point of contact email address;
- point of contact phone number; and
- cost saving measures that PHAs have taken to decrease the likelihood of a shortfall (see PIH Notice 2011-28).
Housing authorities should also review PIH Notice 2013-28 titled “Guidance on the Use of Outside Sources of Funds in the HCV Program.”
HUD’s email guidance can be found here.
NAHRO has learned that the Department of Housing and Urban Development (HUD) has enough money to ensure that February payments for the Housing Choice Voucher (HCV) program and the public housing Operating Fund will be made available to public housing authorities (PHAs). HUD intends to make those payments on time. NAHRO has also learned that there is not currently enough money to make HCV and Operating Fund payments for March, if the government shutdown continues until then.
In order to end the government shutdown, Congress must agree to a funding bill. Now is the time to reach out to your Congresspeople and demand that a fiscal year 2019 appropriations bill for HUD is passed. NAHRO has prepared a letter that can be sent to your Congressional members through the NAHRO Advocacy Action Center.
As PHAs make their voices heard to Congress, NAHRO will continue to fight for you and the families you serve and will continue to inform members as soon as we learn more.
PHAs interested in applying to the first cohort of the Moving to Work (MTW) Expansion must submit their letter of interest to HUD by January 11. Due to the current government shutdown, HUD will not respond to your submitted letter of interest until the government reopens. Regardless, NAHRO recommends that all PHAs interested in applying to the first cohort submit their letters to HUD on or before the January 11 deadline. The HUD notice describing the requirements for letters of interest is here, and letters of interest should be sent to firstname.lastname@example.org. In October 2018, HUD released a notice describing the requirements needed for letters of interest.
PHAs with 1,000 or fewer aggregate units (including special purpose vouchers) are eligible to apply to the first cohort of the MTW Expansion, which will examine the overall impact of MTW flexibility. Before applying, PHAs must complete a baseline research survey that identifies the characteristics of all applicants. After submitting the baseline research survey, PHAs must complete a letter of interest stating a desire to obtain MTW designation, which cannot be longer than two pages and must be signed by the Executive Director. The PHA’s Board of Commissioners must also pass a resolution stating a desire to obtain MTW designation under the first cohort. Lastly, the PHA must also complete a certification of commitment (Attachment I – last few pages).
After the application deadline passes, HUD will divide eligible applicant PHAs into groups based on their geography and then randomly assign each PHA within a geographic area to one of three groups: a treatment group (which will be invited to continue to step 2 to apply); a waitlist group (which may be invited to apply, if a treatment group PHA withdraws); or a control group (which will not receive MTW status, but is expected to participate in the first cohort evaluation). PHAs in the waitlist group will be moved to the control group once the treatment group has 30 PHAs which successfully apply.
NAHRO will continue to monitor the MTW application process and any effects of the government shutdown. We will provide updates as we learn them.
The MTW Operations Notice can be found here.
The first cohort application notice can be found here.
On December 21, HUD published a press release announcing the awarding of $29 million in grants to PHAs and non-profit organizations across the nation to hire or retain service coordinators to help residents find jobs and educational opportunities through the Resident Opportunities and Self Sufficiency Service Coordinators (ROSS-SC) program. According to HUD, the ROSS-SC program “encourages local, innovative strategies that link public housing assistance with public and private resources to enable participating families to increase earned income; reduce or eliminate the need for welfare assistance; and make progress toward achieving economic independence and housing self-sufficiency.”
HUD Secretary Ben Carson noted that “[p]roviding families who live in public housing the opportunity to invest in themselves is a win-win as it helps them to gain economic and housing independence … [t]oday, we’re investing in our residents, offering them the tools they need to build a brighter future for themselves and their children.”
For a list of grant funding by state, see here.
Join Clean Air For All, a joint effort between NAR-SAAH, NAHRO, and Live Smoke Free on third Thursday of the month, for a live discussion and Q&A on the “Instituting Smoke-Free Public Housing” final HUD rule. Participants will hear a brief update on the rule and will be able to submit questions to NAR-SAAH, NAHRO, and Live Smoke Free staff. Have your questions about the rule, cessation resources, and enforcement answered.
These calls are intended for those working and living in affordable housing. The January, March, May, July, September, and November calls will have a housing authority staff focus while the April, June, August, October and December calls will have a resident service provider, resident leader, and resident focus. Everyone is welcome to attend all of the calls and hear the various perspectives.
The January Connect Call will have a guest speaker from Leading Age, the trusted voice for aging in America, will join us to provide tips and strategies for working toward compliance with aging residents in smoke-free public housing.
On December 20, HUD posted in the Public Inspection of the Federal Register a 30-Day Notice of Proposed Information Collection on changes to Admission and Occupancy Requirements for public housing. According to the Information Collection, HUD is making changes to the Admission and Occupancy requirements that “defin[e] an ‘over income family’ as one having an annual income 120 percent above the median income for the area for two consecutive years and includes new mandatory annual reporting requirements on the number of over-income families residing in Public Housing and the total number of families on the Public Housing waiting lists at the end of each reporting year.”
HUD is making these changes in light of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) which included language limiting tenancy of over-income residents in public housing. HUD will use its calculation of very low-income (VLI) to determine income limits. VLIs are preliminarily calculated as 50 percent of the estimated area median family income. VLI limits include several adjustments to align the income limits with program requirements including: high housing cost adjustments, low housing cost adjustments, state and non-metro median family income adjustments, and ceiling and floors for changes. HUD will use the VLI as the basis for the 120 percent income limit by multiplying the VLI limit by a factor of 2.4. Areas without a VLI adjustment would result in an income limit of 120 percent of AMI. Areas with an adjustment would be higher or lower than 120 percent AMI, depending upon the adjustments made.
If a family meets this threshold, public housing authorities (PHAs) have the option of either charging the higher of the fair market rent for the unit or the monthly subsidy (operating and capital fund), or terminating the tenancy within 6 months.
Comments on the proposed notice of information collection are due 30 days after publication in the Federal Register.
Yesterday, in a press release, the administration announced a join action plan by the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), and the Department of Health and Human Services (HHS) to reduce childhood lead exposure and associated health impacts. Secretary Carson has stated that “[i]mplementing this plan will help federal agencies, along with our state and local partners, advance efforts to remediate home health hazards and keep children safe from lead poisoning.”
The plan has four goals:
- Reduce children’s exposure to lead sources;
- Identify lead-exposed children and improve their health outcomes;
- Communicate more effectively with stakeholders; and
- Support and conduct critical research to inform efforts to reduce lead exposure and related health risks.
The plan notes that while it “is not a budget document and does not imply approval for any specific action . . . [i]t will inform future federal budget and regulatory development processes within the context of the goals articulated in the President’s Budget.”
The full press release can be found here.
The action plan can be found here.
Earlier today, HUD broadcast a webinar on the Moving to Work (MTW) Expansion Cohort #1. The webinar explained what MTW was, explained the benefits of an MTW designation, provided presentations from current MTW agencies, and discussed the process by which agencies could apply for Cohort #1. Additionally, questions from webinar participants were answered.
The webinar also gave the following timeline for MTW Expansion activities:
- Spring 2019 – Revise MTW Operations Notice based on public comment and publish final MTW Operations Notice;
- Summer / Fall 2019 – Designate the initial cohort of MTW agencies; invite the second cohort of agencies to apply;
- Winter 2020 – Designate the second cohort of MTW agencies.
The full webinar with audio and the slide presentation will eventually be posted on HUD’s MTW Expansion site, but an unofficial copy of the slides from the webinar can immediately be found here.
Earlier today, the Department of Housing and Urban Development sent an email through its RADBlast! email list announcing RAD rents levels for 2019 (based on 2018 Public Housing Funding Levels). These rents will be used for new awards used in 2019. They may also be used for current awardees to update rents in existing Commitments to enter into Housing Assistance Payment contracts (CHAPs). Closed transactions are ineligible to receive these new rents. Remember, these new rents–after being updated with 2019 Operating Cost Adjustment Factors (OCAFs)–may not necessarily be higher than your current CHAP rents depending on how the transaction is structured. NAHRO strongly recommends carefully reading HUD’s Frequently-Asked-Questions (FAQ) document on updating RAD rents before requesting updated rents.
Additionally, HUD has created a streamlined, online RAD application for public housing conversions that can be accessed here.
The 2019 RAD Rents can be accessed here.
The FAQ can be found here.